United States vs. De Los Reyes and Esguerra

The constitutional guarantee against unreasonable searches and seizures does not render evidence inadmissible if it was obtained from a lawful search incident to a lawful arrest. A person's dwelling is not a sanctuary for crime, and evidence discovered therein during a valid arrest is admissible.

The case arose during the American colonial period under the Philippine Bill of 1903 (the then-applicable constitution), which guaranteed the inviolability of the dwelling. The defendants were charged with illegal possession of morphine, a prohibited drug under Act No. 1761 (the Opium Law).

• Filed in the Court of First Instance (CFI) of Manila.
• The CFI convicted both defendants and sentenced each to six months' imprisonment.
• The defendants appealed directly to the Supreme Court (SC).

• Police officers, armed with an arrest warrant for Valeriano de los Reyes for a different offense (estafa), went to his residence.
• Upon entering, they found Valeriano and Gabriela Esguerra in a room. Gabriela was seen throwing a small box onto a bed.
• The box was found to contain morphine.
• Both were charged with and convicted of violating section 31 of Act No. 1761 (illegal possession of opium or derivatives).

• The prosecution argued that the search was lawful as it was incident to a valid arrest pursuant to a warrant.
• The morphine was discovered in plain view during the execution of the arrest warrant, making it admissible evidence.

• The defendants contended that the search of the dwelling was unlawful and violated the constitutional guarantee against unreasonable searches.
• The evidence (morphine) obtained from this illegal search should be inadmissible ("fruit of the poisonous tree").
• Valeriano argued mere presence in the room was insufficient to prove possession.

• Procedural Issues: N/A
• Substantive Issues:
  1. Whether the search conducted by the police officers was lawful.
  2. Whether the morphine seized was admissible in evidence against the accused.
  3. Whether the evidence sufficiently proved possession by each accused.

• Procedural: N/A
• Substantive:
  1. The search was lawful. The SC ruled the search was a valid incident to a lawful arrest made under a warrant. The officers were authorized to be in the dwelling to execute the arrest warrant for Valeriano.
  2. The evidence was admissible. Since the search was incident to a lawful arrest, the morphine discovered was admissible. The constitutional protection does not shield criminal activity from discovery during a valid police action.
  3. Evidence was insufficient for Valeriano, sufficient for Gabriela. The SC found no evidence that Valeriano had control or knowledge of the morphine beyond his presence. For Gabriela, her act of throwing the box containing the morphine demonstrated possession and an attempt to conceal it.

• Search Incident to a Lawful Arrest — A person lawfully arrested may be searched for weapons or evidence related to the crime for which the arrest is made, without a separate search warrant. The SC applied this to uphold the search of the room where the arrestee (Valeriano) was found.
• Inviolability of Domicile (with Exceptions) — While the constitution protects the dwelling, this protection is not absolute. It does not apply when entry is made pursuant to lawful process (like an arrest warrant) or under other recognized exceptions (e.g., hot pursuit). The SC emphasized that a home cannot be a "shelter of crime."

• "The home, therefore, can not be guaranteed as a shelter of crime and bad faith..."
• "The poorest man may, in his cottage, bid defiance to all the forces of the Crown... but the King of England may not enter; all his force dares not cross the threshold of the ruined tenement." (Quoting Lord Chatham, used to illustrate the principle of domicile inviolability, which the SC then qualified with exceptions).

• United States v. Macaspac — Cited to illustrate that a public official entering a dwelling without proper authority commits a crime, reinforcing the general rule of inviolability.
• United States v. Arceo — Referenced for the general principle that "a man's house is his castle," but distinguished because that case did not involve the use of the dwelling to commit or conceal a crime.

• Section 31, Act No. 1761 (Opium Law) — The statute penalizing the possession of opium or its derivatives, such as morphine.
• Philippine Bill of 1903 (Section 3) — The constitutional provision guaranteeing "the right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures."